Quarterly report pursuant to Section 13 or 15(d)

Income Taxes

v3.23.1
Income Taxes
6 Months Ended
Apr. 01, 2023
Income Taxes [Abstract]  
Income Taxes
Note K—Income Taxes
 
The Tax
 
Cuts and Jobs Act
 
of 2017 enacted on
 
December 22, 2017, significantly revised the
 
U.S. corporate income tax code
 
by, among
 
other things, lowering federal
corporate income tax rates, implementing a
 
modified territorial tax system and imposing a
 
repatriation tax ("transition tax") on deemed repatriated cumulative earnings
of foreign subsidiaries which will be paid
 
over eight years. In addition, new taxes
 
were imposed related to foreign income, including
 
a tax on global intangible low-taxed
income (“GILTI”) as well as a limitation on the
 
deduction for business interest expense
 
(“Section 163(j)"). GILTI is the excess of the shareholder’s
 
net controlled foreign
corporations net tested income over the
 
net deemed tangible income.
 
GILTI income is eligible for a deduction of up to 50%
 
of the income inclusion, but the deduction is
limited to the amount of U.S. adjusted
 
taxable income.
 
The Section 163(j) limitation does not
 
allow the amount of deductible interest to
 
exceed the sum of the taxpayer's
business interest income and 30% of the taxpayer’s adjusted taxable
 
income. We have included in our calculation of our effective tax rate the estimated impact of GILTI
and Section 163(j).
 
In addition, we
 
have elected to
 
account for the
 
tax on GILTI
 
as a
 
period cost and,
 
therefore, do not
 
record deferred taxes
 
related to GILTI
 
on our
foreign subsidiaries.
 
Our effective income tax
 
rate on operations for the
 
six-months ended March 2023 was
27.5
% compared to a rate
 
of
18.2
% in the same
 
period of the prior year,
 
and an
effective rate of
17.9
% for fiscal 2022. We generally benefit from having income in
 
foreign jurisdictions that are either exempt from income taxes or have tax rates that
are lower
 
than those
 
in the
 
United States.
 
As such,
 
changes in
 
the mix
 
of U.S.
 
taxable income
 
compared to
 
profits in
 
tax-free or
 
lower-tax jurisdictions
 
can have
 
a
significant impact on our overall effective tax rate. The current year tax
 
rate decreased relative to prior periods due US losses expected
 
to generate a US tax benefit.